Is North Korean Labor used in your supply chains? Beware of the Countering America’s Adversaries Through Sanctions Act (CAATSA).

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Is North Korean Labor used in your supply chains? The answer should be no, and if you are not sure, then you need to be aware of the Countering America’s Adversaries Through Sanctions Act (CAATSA).

In early December, U.S. Customs and Border Protection (CBP) authorized the detention of merchandise from multiple China-based companies – Jingde Trading Ltd., Rixin Foods. Ltd., and Zhejiang Sunrise Garment Group Co. Ltd. at all U.S. ports.

This enforcement action is the result of a CBP investigation indicating that these companies use North Korean labor in their supply chains in violation of the Countering America’s Adversaries Through Sanctions Act (CAATSA).

The CAATSA prohibits any goods that are produced, or manufactured in whole or in part by North Korean nationals or North Korean citizens anywhere in the world – unless the importer or manufacturer can provide clear and convincing evidence the goods were not made by convict labor, forced labor, or indentured labor.

To enforce the CAATSA – CBP can detain any merchandise suspected of violating CAATSA at all ports of entry into the US.

If you have received notice of a CAATSA violation – please note, you have 30 days to provide clear and convincing evidence forced labor was not used. If you have received a notice – contact David Hsu immediately by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com; DH@GJATradeLaw.com.

Any delay may result in seizure and or forfeiture of your goods. Also, if you are aware of any company or manufacturer importing goods made in violation of CAATSA, please also contact David Hsu by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com; DH@GJATradeLaw.com. All communications are confidential and subject to attorney/client privilege.

CBP seizes 4.6 million disposable gloves due to forced labor finding.


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According to a U.S. Customs and Border Protection (CBP) media release, officers in Missouri seized over 4.68 million latex gloves from a subsidiary of Malaysia based Top Glove Corporation Bhd. The seizure valued at $690,000 was due to information provided to CBP the gloves were manufactured using forced labor – a form of modern slavery.

Specifically, CBP issued a forced labor finding – in which they suspect Top Glove’s production process to include debt bondage, excessive overtime, abusive working conditions, abusive living conditions and the retention of identity documents.

Unfortunately for Top Glove, CBP will continue seizing their goods until Top Glove can prove future glove shipments were not produced using forced labor. In general, forced labor also includes indentured labor, use of convict labor, and child labor.

CBP issued a forced labor finding on March 29 based on evidence of multiple forced labor indicators in Top Glove’s production process, including debt bondage, excessive overtime, abusive working and living conditions, and retention of identity documents.

If your company is suspected of using forced labor. contact David Hsu anytime by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com. Forced labor compliance is the new, hot enforcement area for Customs and Border Protection.

If you are an importer, and are concerned about forced labor accusations, contact us also to create your forced labor compliance program.

CBP revokes WRO on tuna harvested by the Tunago 61 vessel.

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According to a U.S. Customs and Border Protection media release – CBP announced that tuna and tuna products harvested from the Tunago No.61 vessel will be admissible at all U.S. ports of entry beginning April 1, 2020.

The revocation of withhold release order (WRO) on tuna and tuna products harvested from the Tunago No. 61 vessel was based on information provided to CBP that tuna and tuna products from this vessel are no longer produced under forced labor conditions.

A WRO is put in place prohibiting the importation of certain goods if CBP believes the goods being imported were made wholly or in part by forced labor, including convict labor, forced child labor, and indentured labor.

If you are subject to a pending WRO and want to discuss your options, or if you are aware of an importer using any type of forced labor; contact experienced customs attorney David Hsu by phone/text at 832-896-6288 or by email at attorney.dave@yahoo.com.